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Effective July 8, 2026, the Consumer Product Safety Commission (CPSC) will require eFiling for most regulated consumer products. For regulated consumer products entered into a Foreign Trade Zone (FTZ), the eFiling requirements will take effect on January 8, 2027. CPSC’s list of products likely subject to mandatory eFiling is available here.
Prior to the effective date, importers should meet with their trade and product safety teams to review the eFiling process, gather the requisite certificates, and consider joining the eFiling voluntary stage. Joining the voluntary stage gives importers, their brokers, and their product safety teams the opportunity to learn the eFiling system and make the appropriate adjustments before eFiling becomes mandatory. Errors during the voluntary stage will not cause shipping delays. Importers interested in self-registering for the voluntary stage can do so here.
Importers who have joined the voluntary stage should work with their brokers and product safety teams to ensure that all required information—including products’ certificate data, certifier ID, product ID, and version ID—is properly entered in CPSC’s registry. Teams may find it helpful to test this by taking a single product through the entry filing and certificate data components of the full eFiling process.
Importers should also test the product registry’s certificate data storage functionalities during the voluntary stage. As the registry only allows importers to archive certificates or trade parties (rather than delete them), data entered into the registry will permanently exist there. Importers are therefore encouraged not to populate the registry with large quantities of test data. The current eFiling certificate registry includes business-account-administrator-managed “product collections,” and CPSC is likely to add management features for trade parties in order to enhance organization and promote flexibility that suits importers’ unique needs.
“Flagging” products is insufficient for eFiling purposes, so it is crucial that importers and their teams convene to determine which products have the proper certificates. Following the eFiling effective date, importers who do not submit eFiling data for products with certificate requirements face increased likelihood that their shipments are stopped, held, or examined; this increases importers’ likelihood of receiving CPSC violations. Similarly, importers should only use Disclaimer Message Sets (DMS) when no certificate is required, and importers who use DMS to avoid submitting required certificates may face violations. Disclaims do not save in the product registry.
Ultimately, CPSC is digitizing the certificate information already required upon entry. As certification and import requirements have not changed, CPSC’s regulatory scheme remains the same.
For further information, see the CPSC eFiling Implementation Guide. Braumiller Law Group will provide any updates as they become available.
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